- 2 - other court, and this opinion shall not be treated as precedent for any other case. This matter is before the Court on respondent’s Motion To Dismiss For Lack Of Jurisdiction, filed June 1, 2007, and supplemented June 13, 2007. In his motion, respondent moves to dismiss this case for lack of jurisdiction principally on the ground that “no Notice of Determination Concerning Collection Actions Under Section 6320 and/or Section 6330, as authorized by I.R.C. § 6320 and required by I.R.C. § 6330(d) to form the basis for a petition to this Court, has been sent to petitioners with respect to taxable years 1995, 1998, 2002 and 2003”. Respondent also moves to dismiss on the ground that “as to the IRS filed Notice of Federal Tax Lien which is attached to the petition, said lien was released on February 14, 2007, and the liability fully paid”. For reasons discussed hereinafter, we shall grant respondent’s motion, as supplemented, in that we shall dismiss this case for lack of jurisdiction on the ground that no notice of determination was sent to petitioners by respondent’s Office of Appeals for any of the taxable years in issue. Background At the time that the petition was filed, Zane D. Worman and Debbie L. Worman (petitioners) resided in Gillette, Wyoming. For 1995, 1998, 2002, and 2003, the taxable years in issue, petitioners filed Federal income tax returns. AlthoughPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007